E Document Framework - GST India
E Document Framework - GST India
E Document Framework - GST India
The GST Council has approved introduction of ‘E-invoicing’ or ‘electronic invoicing’ in a phased
manner for reporting of business to business (B2B) invoices to GST System, starting from 1st
January 2020 on voluntary basis. Since there was no standard for e-invoice existing in the country,
standard for the same has been finalized after consultation with trade/industry bodies as well as
ICAI after keeping the draft in public place. Having a standard is a must to ensure complete inter-
operability of e-invoices across the entire GST eco-system so that e-invoices generated by one
software can be read by any other software, thereby eliminating the need of fresh data entry –
which is a norm and standard expectation today. The machine readability and uniform
interpretation is the key objective. This is also important for reporting the details to GST System
as part of Return. Apart from the GST System, adoption of a standard will also ensure that an e-
invoice shared by a seller with his buyer or bank or agent or any other player in the whole business
eco-system can be read by machines and obviate and hence eliminate data entry errors.
The GST Council approved the standard of e-invoice in its 37th meeting held on 20th Sept 2019
and the same along with schema has been published on GST portal. Standards are generally
abstruse and thus an explanation document is required to present the same in common man’s
language. Also, there are lot of myth or misconception about e-Invoice. The present document is
an attempt to explain the concept of e-invoice, how it operates and basics of standards. It also
contains FAQs which answer the questions raised by people who responded to the draft e-invoice
standard used for public consultation. It is expected that the document will also be useful for the
taxpayers, tax consultants and the software companies to adopt the designed standard.
A. What is e-invoice?
If an invoice is generated by a software on the computer or Point of Sales (PoS) machine then does
it become an e-invoice? Is e-invoice as a system where taxpayers can generate the invoices
centrally? Many such questions are raised when e-invoice gets discussed.
E-invoice does not mean generation of invoices from a central portal of tax department, as any
such centralization will bring unnecessary restriction on the way trade is conducted. In fact,
taxpayers have different requirements and expectation, which can’t be met from one software
generating e-invoices from a portal for the whole country. Invoice generated by each software
may look more or less same, however, they can’t be understood by another computer system even
though business users understand them fully. For example, an Invoice generated by SAP system
cannot be read by a machine which is using ‘Tally’ system. Likewise there are hundreds of
accounting/billing software which generate invoices but they all use their own formats to store
information electronically and data on such invoices can’t be understood by the GST System if
reported in their respective formats. Hence a need was felt to standardize the format in which
electronic data of an Invoice will be shared with others to ensure there is interoperability of the
data. The adoption of standards will in no way impact the way user would see the physical (printed)
invoice or electronic (ex pdf version) invoice. All these software would adopt the new e-Invoice
standard wherein they would re-align their data access and retrieval in the standard format.
However, users of the software would not find any change since they would continue to see the
physical or electronic (PDF/Excel) output of the invoices in the same manner as it existed before
incorporation of e-Invoice standard in the software. Thus the taxpayer would continue to use his
accounting system/ERP or excel based tools or any such tool for creating the electronic invoice as
s/he is using today.
To help small taxpayers adopt e-invoice system, GSTN has empaneled eight accounting & billing
software which provide basic accounting and billing system free of cost to small taxpayers. Those
small taxpayers who do not have accounting software today, can use one of the empaneled software
products, which come in both flavors, online (cloud based) as well as offline (installed on the
computer system of the user).
GST Council has given the responsibility to design the standard of e-invoice and update the same
from time to time to GSTN which is the custodian of Returns and invoices contained in the same.
Adoption of e-invoice by GST System is not only part of Tax reform but also a Business reform
as it make the e-invoices completely inter-operable eliminating transcription and other errors.
Objectives Outcome
Efficiency in
tax • Elimination of fake invoices
administration
Generation of e-invoice will be the responsibility of the taxpayer who will be required to report
the same to Invoice Registration Portal (IRP) of GST, which in turn will generate a unique Invoice
Reference Number (IRN) and digitally sign the e-invoice and also generate a QR code. The QR
Code will contain vital parameters of the e-invoice and return the same to the taxpayer who
generated the document in first place. The IRP will also send the signed e-invoice to the recipient
of the document on the email provided in the e-invoice.
Note: To begin with, there will be only one IRP, but more IRPs will be added to provide higher
availability, redundancy, speed and a diversified and distributed service to tax payers with a
choice.
i. Invoice by Supplier
ii. Credit Note by Supplier
iii. Debit Note by Supplier
iv. Any other document as required by law to be reported by the creator of the
document
Note: Seller should have a utility that will output invoice data in JSON format, either from his
accounting or billing software or his ERP or excel/word document or even a mobile app. Those
who do not use any accounting software or IT tool to generate the invoice, will be provided an
offline tool to key-in data of invoice and then submit the same. The small and medium size
taxpayers (having annual turnover below Rs 1.5 Crores) can avail accounting and billing system
being offered by GSTN free of cost.
Step 2 is to generate the unique Invoice Reference Number (IRN) (in technical terms hash of 3
parameters using a standard and well known hash generation algorithm e.g. SHA256). This is an
optional step. The seller can also generate this and upload along with invoice data. The 3
parameters which will be used to generate IRN (hash) are:
i. Supplier GSTIN,
ii. Supplier’s invoice number and,
iii. Financial year (YYYY-YY). (The IRN or hash generation algorithm will be
prescribed by GSTN in the e-invoice standard).
Step 3 is to upload the JSON of the e-invoice (along with the hash, if generated) into the IRP by
the seller. The JSON may be uploaded directly on the IRP or through GSPs or through third party
provided Apps.
Step-4: The IRP will also generate the hash and validate the hash of the uploaded json, if uploaded
by the supplier. The IRP will check the hash from the Central Registry of GST System to ensure
that the same invoice from the same supplier pertaining to same Fin Year is not being uploaded
again. On receipt of confirmation from Central Registry, IRP will add its signature on the Invoice
Data as well as a QR code to the JSON. The QR code will contain GSTIN of seller and buyer,
Invoice number, invoice date, number of line items, HSN of major commodity contained in the
invoice as per value, hash etc. The hash computed by IRP will become the IRN (Invoice
Reference Number) of the e-invoice. This shall be unique to each invoice and hence be the unique
identity for each invoice for the entire financial year in the entire GST System for a taxpayer. [GST
Systems will create a central registry where hash sent by all IRPs will be kept to ensure uniqueness
of the same].
Step 5 will involve sharing the uploaded data with GST and e-way bill system. More details are
given in Part-B below.
Step 6 will involve returning the digitally signed JSON with IRN back to the seller along with a
QR code. The registered invoice will also be sent to the seller and buyer on their mail ids as
provided in the invoice.
Part B: Flow from IRP to GST System/E-Way Bill System & Buyer
The following diagram shows how e-Invoice data would be consumed by GST System for
generation of e-way bill or populating relevant parts GST Returns, stated in Step-5 above.
Step 5 (a) will be to share the signed e-invoice data along with IRN (same as that has been returned
by the IRP to the seller) to the GST System as well as to E-Way Bill System.
Step 5b The GST System will update the ANX-1 of the seller and ANX-2 of the buyer, which in
turn will determine liability and ITC.
Step 5c E-Way bill system will create Part-A of e-way bill using this data to which only vehicle
number will have to be attached in Part-B of the e-way bill.
Note 1: The e-invoice standardized schema has mandatory and optional items. The e-invoice shall
not be accepted in the GST System unless all the mandatory items are present. The optional items
are to be used by the seller and buyer as per their business need to enforce their business
obligations or relationships.
Note 2: Seller may send his e-invoice for registration to more than one registrar. But the GST
system and IRP will perform a de-duplication check with central registry to ensure that the IRN
that is generated is unique for each invoice. Therefore, the IRP shall return ONLY ONE registered
IRN for each invoice to the seller. In case of multiple registrars (more than one IRPs) only one
IRP will return a valid IRN to the seller. Except one, all other IRPs will reject the request of
registration.
Note 3: The QR code will enable quick view, validation and access of the invoices from the GST
system from hand held devices.
Small taxpayers can use one of the eight free accounting/billing software currently listed by GSTN.
Also, GSTN will provide Offline Tool where data of an invoice, generated on paper can be entered
which in turn will create JSON file for uploading on the IRP. Taxpayers can also use one of the
commercially available accounting/billing software for this purpose. All accounting and billing
software companies are being separately asked to adopt the e-invoice standard so that their users
can generate the JSON from the software and upload the same on the IRP.
The unique IRN will be based on the computation of hash of GSTIN of generator of document
(invoice or credit note etc.), Year and Document number like invoice number. This hash will be
as published in the e-invoice standard and unique for this combination. This way hash will always
be the same irrespective of the registrar who processes it. The hash could also be generated by the
taxpayers based on above algorithm. The providers of accounting and billing software are being
separately asked to incorporate this feature in their product. One can pre-generate and print it on
the invoice book, however, the same will not make the invoice valid unless it is registered on the
portal along with invoice details.
Note: The hash algorithm that is to be used by the taxpayers has been specified in the e-invoice
standard that is published. The hash will be the IRN.
To ensure deduplication, the registrar will be required to send the hash to Central Registry of GST
System to confirm whether the same has been reported already. In case it has been reported by
another registrar (as and when more registrars – IRPs – are added) and the Central Registry already
has the same IRN, then the registrar will reject the registration and inform the sender. Only unique
invoices from a taxpayer will be accepted and registered by the registrar.
Digital Signing by e-Invoice Registration Portal: The invoice data will be uploaded on the IRP
(Invoice Registration Portal), which will also generate the hash in order to verify it and then
digitally sign it with the private key of the IRP. In case the taxpayer submits hash also along with
invoice data, the same will be validated by IRN system. The IRP will sign the e-invoice along with
hash and the e-invoice signed by the IRP will be a valid e-invoice and used by GST/E-Way bill
system.
QR Code: The IRP will also generate a QR code containing the unique IRN (hash) along with
some important parameters of invoice and digital signature so that it can be verified on the central
portal as well as by an Offline App. This will be helpful for tax officers checking the invoice on
the roadside where Internet may not be available all the time. The web user will get a printable
form with all details including QR code. The QR code will consist of the following e-invoice
parameters:
a. GSTIN of supplier
b. GSTIN of Recipient
c. Invoice number as given by Supplier
d. Date of generation of invoice
e. Invoice value (taxable value and gross tax)
f. Number of line items.
g. HSN Code of main item (the line item having highest taxable value)
h. Unique Invoice Reference Number (hash)
The offline app will be provided on the IRP for anyone to download to authenticate the QR code
of the invoice offline and its basic details. However, to see the whole invoice, one will have to
connect to the portal and verify and see the details online. The facility to download entire invoice
will be provided to tax officers, the way it is currently available under E-way bill system.
Note 4: The facility of QR code verification will be made available only through the GST System
and not the IRP. This is because the IRP will not have the mandate to store invoices for more than
24 hours. In order to achieve speed and efficiency, the IRP will be a lean and focused portal for
providing invoice registration and verification service, IRN and the QR codes. Hence, storing of
the invoices will not be a feature of the IRP.
Multiple Registrar for IRN System: Multiple registrars (IRPs) will be put in place to ensure
24X7 operations without any break. To start with, NIC will be the first Registrar. Based on
experience of the trial more registrars will be added.
Standardization of Invoice: A technical group constituted by the GST Council Secretariat has
drafted standards for e-invoice after having industry consultation. The e-invoice schema and
template, as approved by the GST Council, are available at https://www.gstn.org/e-invoice/.
H. CREATION OF E-INVOICE
Modes for getting invoice registered: Multiple modes will be made available so that taxpayer
can use the best mode based on his/her need. The modes given below are envisaged at this stage
under the proposed system for e-invoice, through the IRP (Invoice Registration Portal):
a. Web based,
b. API based,
c. SMS based,
d. mobile app based,
e. offline tool based and
f. GSP based.
API mode: Using API mode, the big tax payers and accounting software providers can interface
their systems and pull the IRN after passing the relevant invoice information in JSON format. API
request will handle one invoice request at time to generate the IRN. This mode will also be used
for bulk requirement (user can pass the request one after the other and get the IRN response within
fraction of second) as well. The e-way bill system provides the same methodology.
Printing of Invoice
The taxpayer can continue to print his paper invoice as he is doing today including logo and
other information. E-invoice schema only mandates what will be reported in electronic format to
IRP.
General Questions on e-invoice system
Amendment/cancellation of e-invoice
1. Whether e-invoices generated through GST system can be partially/fully cancelled?
a. E-Invoice can’t be partially cancelled. It has to be fully cancelled.
b. The e-invoice mechanism enables invoices to be cancelled. This will have to be
reported to IRN within 24 hours. Any cancellation after 24hrs could not be
possible on IRN, however one can manually cancel the same on GST portal
before filing the returns.
2. How would amendments be allowed in e-invoice?
a. Amendments to the e-invoice are allowed on GST portal as per provisions of
GST law. All amendments to the e-invoice will be done on GST portal only.
Relationship with e-way bill
1. With the introduction of e-invoices, what are the documents need to be carried during
transit of goods?
a. For transportation of goods, the e-way bill will continue to be mandatory, based
on invoice value guidelines, as hitherto fore. This aspect will be notified by the
Government when this mechanism will be notified.
Export/Import
1. Please clarify whether exports would require e-invoice compliance.
a. Yes.
b. The e-invoice schema also caters to the export invoices as well. The e-invoice
schema is based on most common standard, this will help buyer’s system to
read the e-invoice.
2. Does the e-invoice allow the declaration of export invoices/ zero rated supplies?
a. Yes.
b. It allows the declaration of export invoices / zero rated supplies.
Others
1. What will be the workflow of the end to end e-invoice mechanism?
a. The end to end workflow will be provided by at the time of rollout of the e-
invoice system.
2. Will the industry be provided sufficient time for preparation?
a. Yes.
b. The e-invoice mechanism is expected to be rolled out in phases from 01st Jan
2020 on voluntary basis.
c. Initially, the e-invoice mechanism will be allowed for tax payers above a
certain turnover or above a certain invoice value or also to volunteers.
d. Subsequently, it will be enabled for all tax payers in a phased step-wise
manner.
e. Details of these will be published subsequently.